Centers for Medicare and Medicaid Services (Photo: CMS) Centers for Medicare and Medicaid Services (Photo: CMS)

The Affordable Care Act public exchange system is making a change that could help some people avoid tax nightmares but cause some other people to suffer a sudden, unexpected loss of ACA exchange plan health coverage.

The public exchange programs will be automatically ending the exchange plan coverage of many exchange plan users who appear to have Medicare coverage.

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Officials from the Centers for Medicare and Medicaid Services (CMS) talk about the new, automatic expulsion effort in a guide to the “periodic data matching” effort that was released Wednesday.

The Background

The ACA exchange plan program gives low-income and moderate-income people a way to use ACA premium tax credit subsidies to help pay for coverage.

Medicare is a federal health insurance program that serves people ages 65 and older, many younger people who qualify for Social Security Disability Insurance benefits, and people who need kidney dialysis.

Under federal law, people are not supposed to use ACA premium tax credit subsidies and have Medicare coverage at the same time. ”Double dippers” may have to return any ACA premium tax credits they received while on Medicare, when they file their federal income tax returns.

CMS and the exchange programs have been trying to locate ACA exchange-Medicare double dippers every year since 2015.

The 2019 Change

The 2019 Medicare periodic data matching will probably be different, because CMS now has better data matching information technology, officials say in the new Medicare data matching program guide.

The new technology  “allows the exchange to take action and end a consumer's [ACA subsidies] if they're found to be dually enrolled in Medicare and an exchange health plan,” officials say. “Beginning in 2019, the exchange will now also end exchange health plan coverage for consumers who permit the exchange to take this action if they're found to be dually enrolled at a later date.”

Nuts and Bolts for Agents

Here are some 2019 Medicare data matching program details that could be of interest to producers who are trying to help consumers understand data matching program notices, or resolve coverage cancellation problems.

In some cases, an ACA exchange will cancel a suspected double dipper's exchange plan coverage along with the subsidy money.

The exchange may cancel a suspected double dipper's exchange plan coverage automatically if the suspected double dipper gave the exchange permission to do so, by saying “yes” to a question in the exchange application.

An affected consumer will have 30 days from the date the notice is sent to respond to the notice.

If a consumer has given an exchange permission to cancel double dipper exchange plan coverage automatically, then the exchange can cancel the suspected double dipper's ACA subsidies, and health coverage, after the 30-day response window has ended.

Consumers may give an exchange permission to end their exchange plan health coverage, as well as their ACA subsidy support, automatically, if the exchange discovers that the consumers are Medicare-exchange plan double dippers. The question authorizing automatic coverage terminations is in the exchange program application.

Exchanges may send Medicare periodic data matching notices throughout the year.

Consumers who believe that they are still eligible to keep their coverage in place can file appeals. A consumer must send the appeal to the U.S. Department of Health and Human Services' Marketplace Appeals Center. “Consumers will receive instructions on how to appeal the exchange's determination in the final [periodic data matching] notice outlining the action that the exchange will be taking,” officials say in the data matching program guide.

Resources

A copy of the Medicare data matching guidance is available here.

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Allison Bell

Allison Bell, a senior reporter at ThinkAdvisor and BenefitsPRO, previously was an associate editor at National Underwriter Life & Health. She has a bachelor's degree in economics from Washington University in St. Louis and a master's degree in journalism from the Medill School of Journalism at Northwestern University. She can be reached through X at @Think_Allison.